Lamont Management Ltd. v. The Queen, 2000 DTC 6256 (FCA)

Safe income attributable to shares of a Canadian corporation ("Canpac") that were purchased for cancellation in the hands of the taxpayer included safe income of a foreign corporation in which Canpac had an indirect equity interest of less than 10% and which did not qualify as a foreign affiliate of Canpac. There was no absurdity in safe income attributable to a foreign non-affiliate being calculated without reference to the specific rules applicable to other types of corporations under s. 55(5).

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